September 5, 2014

Via eTariff

The Honorable Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, DC 20426

Re: NSTAR Electric Company and ISO New England Inc. Filing of Local Service Agreement; Docket No. ER14-2596-000

Dear Secretary Bose:

Pursuant to Section 205 of the Federal Power Act (“FPA”)1 and Part 35 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission2 (the “Commission”), ISO New England Inc. (“ISO-NE”)3 and NSTAR Electric Company (“NSTAR”) (together,“Filing Parties”) hereby submit an amendment to the filing made on August 5, 2014 in this proceeding of a Local Service Agreement by and among NSTAR, Massachusetts Bay Transportation Authority (“MBTA”), and ISO-NE for Local Network Service under Schedule 21-NSTAR of the ISO-NE OATT (the “MBTA LSA”).

the

4

In the August 5th filing, Attachment 2 of the MBTA LSA provided an example calculation of the Direct Assignment Charge assessed pursuant to the MBTA LSA. While the

1 16 U.S.C. § 824d (2006).

2 18 C.F.R. Part 35 (2011).

3 NSTAR, and not ISO-NE, has the FPA section 205 rights over Schedule 21-NSTAR of the ISO-NE Open Access Transmission Tariff (“OATT”), pursuant to which NSTAR offers and administers Local Service. ISO-NE does not offer or administer Local Service and joins this filing solely to fulfill its obligations to file Local Service Agreements on behalf of the applicable Participating Transmission Owner (“PTO”), in accordance with Article 3.03(d)(ii) of the Transmission Operating Agreement between ISO-NE and the PTOs. See ISO New England Inc., 124 FERC ¶ 61,297 (2008).

4 The MBTA LSA has been designated as Original Service Agreement No. TSA-NSTAR-001 under Schedule 21-NSTAR of Section II of the ISO-NE OATT (“Schedule 21-NSTAR” or “Local Service Schedule”).

Honorable Kimberly D. Bose September 5, 2014 Page 2 calculations shown on Attachment 2 are correct, two of the column headings were misstated. Because this inadvertent error could lead to confusion, the Filing Parties desire to replace the MBTA LSA originally filed on August 5, 2014 with the MBTA LSA included herewith. Other than the Attachment 2 headings which have been corrected, all other provisions of the MBTA LSA remain unchanged from the August 5th filing.

The Filing Parties respectfully request that the Commission accept the amended MBTA LSA attached hereto, without modification or condition, effective May 1, 2014. The Filing Parties respectfully request any waivers of the Commission’s regulations, including but not limited to, 18 C.F.R. §§ 35.3 35.11, and 35.15, that may be necessary so as to permit the requested effective date.

Good cause exists to grant the requested effective date in this case, as NSTAR, MBTA, and ISO-NE have agreed to the terms and conditions of the MBTA LSA which lowers the rate for one of the MBTA’s 59 Points of Delivery, all other aspects of the MBTA LSA being identical to the pro forma Local Service Agreement in Schedule 21-Common. The Commission has granted waivers when “all affected parties have had sufficient notice.”5 The MBTA LSA is fully executed,6 memorializing the intent of all parties involved. Further, permitting this effective date will allow the agreement to go into effect on the earliest date desired by the MBTA.

To the extent that the Commission finds otherwise, the Filing Parties request as early an effective date as the Commission may allow.

WHEREFORE, the Filing Parties respectfully request that the Commission grant the requested waivers and accept the MBTA LSA for filing effective May 1, 2014.

Respectfully submitted, /s/ Monica Gonzalez Monica Gonzalez Senior Regulatory Counsel ISO New England Inc. One Sullivan Road Holyoke, MA 01040 (413) 535-4000 Fax: (413) 535-4379 mgonzalez@iso-ne.com Counsel for ISO New England Inc.

5 See California Independent System Operator Corp., 111 FERC ¶ 61,073 at P 26 (2005).

6 The MBTA LSA was not executed by any of its three parties prior to May 1, 2014, and was only fully executed on June 5, 2014. The Filing Parties have been authorized to state that the MBTA consents to the filing of the amended MBTA LSA, as well.

Honorable Kimberly D. Bose September 5, 2014 Page 3

/s/ Mary E. Grover Mary E. Grover, Esq. Northeast Utilities Service Company 800 Boylston Street, P1700 Boston, MA 02199-8003 (617) 424-2105 mary.grover@nu.com

Counsel for NSTAR Electric Company

Enclosures cc: Massachusetts Bay Transportation Authority

ATTACHMENT A

EXECUTED LOCAL SERVICE AGREEMENT

Attachment 2

This example does not change, nor is it a substitute for, the other provisions of this Local Service Agreement. If an inconsistency between this Attachment 1 example and the other provisions of the Local Service Agreement arises, the other provisions of the Local Service Agreement shall control.

(1) (2) (3) (4)=(1)/(3) (5)=(2)x(4)2012 Total Boston 2012 Total Boston Substation Annual

Municipal Gross Plant Gross Plant Property Cost of Facilities (a) Tax Expense Year-End Balance Allocation Factor Tax

1 $1,766,750 $53,977,652 $2,020,726,269 0.09% $47,176

(a) Original Cost of Facilities

using 2012 actual data

NSTAR ElectricExample Calculation of the Annual Property Tax charge to MBTA (Massachusetts Bay Transportation Authority)

(1) (2) (3) (4)=(1)/(3) (5)=(2)x(4) (6) (7)=(5)+(6)2012 Actual Actual Annual Annual Total

2012 Actual NSTAR Year-End Gross Gross Plant O&M/A&G Property Annual Cost of Facilities (a) NSTAR O&M/A&G (b) Transmission plant (c) Allocation Factor Charge Tax Charge

1 $1,766,750 $36,194,862 $1,518,437,029 0.12% $42,131 $47,176 $89,307

(a) Original Cost of Facilities

(b) Actual data per FERC Form 1 and allocated to Transmission:Transmission O&M $21,631,882Transmission A&G $13,676,422Payroll Taxes $886,558

$36,194,862

(c) Actual data per NSTAR Electric's FERC Form 1:2012 year end gross transmission plant $1,529,707,780Less: 2012 year end gross Dispatch Center T Plant ($11,270,751)

$1,518,437,029

using 2012 actual data

NSTAR ElectricExample Calculation of the Annual O&M/A&G and Taxes charge to MBTA (Massachusetts Bay Transportation Authority)